Policies

Anti Bribery and Anti-corruption Policy adopted by Sizer Group.

The Values and Models extends to all the company’s domestic and foreign operations, including operations conducted by any departments, subsidiaries, agents, consultants or other representatives in which Sizer group is a participant.

Sizer group Policy of Anti Bribery & Anti corruption (ABAC) extends to all of the company’s financial record-Keeping activities and is integrated with the obligation to which company is already subject by virtue of State securities laws.

Sizer group conducts periodic reviews of its corporate policies and compliance programs regarding the ABAC laws of each jurisdiction to which the company, its officers, employers, employee, agents contractors, sub-contractors, affiliates and subsidiaries may be subject.

Sizer group ABAC policy extents in keeping provisions to keep its books, records and accounts in reasonable details, accurately and such that they fairly reflect all transactions and dispositions of assets.

Sizer group ABAC aims at prohibiting the mischaracterization or omission of any transaction on a company’s books or any failure to maintain proper accounting controls that results in such a mischaracterization or omission. Sizer group aims in keeping detailed accurate description of all payments and expenses while complying the Sizer group ABAC ethics.

Sizer group ABAC due diligence and selection of third Party Rep. and business partner: Sizer Group competes for all business opportunities fairly, ethically and legally and will negotiate contracts in a fair and open manner. Regardless of any unknown pressure from any local region, Sizer group will conduct business using only legal and ethical means. Sizer group employees shall follow company’s requirement governing investigating, pre-qualifying, certifying and entering into agreements with Third parties who will act on behalf of the company in international transaction. A Third party may be selected only after careful consideration of appropriate information. The Third party must agree to all appropriate monitoring and audit procedures by the company or its designee.

All active participants of Sizer group is expected to read and understand and comply Sizer group ABAC models.

Any of the Sizer employees, who learn of a violation or suspected violation of ABAC are instructed to contact the Management of Sizer group without any delay in an attempt to minimize the impact.

Any individuals who violates the above code is subject to immediate dismissal of his/her position and subject to investigation by the state laws

Responsible Supply

As a leading company in the Metal industry, we are committed to ensuring that the Metal under our control is responsibly and ethically sourced.

Over the last decade, quantities of Tin (and other "conflict" metals such as Copper, tungsten and gold)have entered the global supply chain from locations, particularly war-torn parts of the Democratic Republic of Congo (DRC), where the ore has been mined illegally or without regard and commitment to health, safety, environment, labour conditions and human rights.

We have had a long-term commitment to working closely with our industry, including the end-users of Tin products, to put in place strategies that will ensure the responsible supply of Tin material.

For this reason we are an active member of the iTSCi and support its creation of a comprehensive set of tools and processes to enable the credible implementation of a Code of Conduct throughout the supply chain. We adhere closely to the Conflict Minerals policies of the EICC and participate actively in the Conflict Free Smelter program.

Conflict Free Policy (Effective 15-December-2014)

As a leader in Metal Sourcing, serving the end consumers of tin metal products, Sizer Metals Pte Ltd, Singapore is highly committed to offering the safest work environment to our employees and contractors and in ensuring that our work practices are environmentally responsible. This policy is further reflected in our commitment to serving as an industry champion for a conflict-free supply chain.

In our pursuit to eliminate the unlawful and immoral activities surrounding the trade and use of minerals mined in conflict-affected areas, Sizer Metals joined the ITSCII in 2016. The EICC, comprised of leading companies throughout the electronics industry, strives to improve working conditions, ethics, and environmental stewardship throughout the complex electronics industry supply chain. As an active member of the ITSCII, Sizer Metals Pvt. Ltd. have been subject procurement only rigorous Conflict Free Smelter audit program and we proudly maintain a "Conflict-Free Smelter" status.

Our mission is to drive awareness throughout the industry so that all Tin conflict materials are eliminated from all industry supply chains. To fulfill this mission Sizer metals commits to the following actions:

  • Work cooperatively with organizations and agencies such as the ITSCII, ITRI and EICC Organization for Economic Cooperation and Development (OECD), International Tin Research Institute (ITRI), and International Conference on the Great Lakes Region (ICGLR) to establish credible and effective processes that isolate and eliminate non-ethical Tin mining and trade, and allow continuation of legitimate activity in "conflict regions."

  • Support the ongoing efforts by relevant authorities that have the potential to ensure legitimate, socially responsible commerce and bring sustainable improvements in living conditions and economic stability in conflict-regions.

  • Comply with applicable legislation such as, the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act (July, 2010), which encourages legitimate, conflict-free trade of minerals sourced from the Democratic Republic of the Congo (DRC) and the Great Lakes Region of Africa.

  • Ensure that all purchases from "conflict regions" such as the DRC, comply with the applicable requirements of the OECD Due Diligence Guidance for Responsible Supply Chains.

  • Require that all Sizer metals shipments of Tin containing material adhere to the appropriate domestic and international transportation regulations, including Class 7, Radioactive Materials. Sizer metals advocates the tin Industry also complies with these international regulations.

  • Communicate our ethical and sustainable sourcing policy to our suppliers, employees, customers and investors and perform internal monitoring of our performance to these standards.

We strongly encourage all organizations involved in Tin mining, manufacturing, or the use of Tin products to join us in keeping conflict minerals out of our supply chain.

POLICY ON ANTI-COMPETITIVE BUSINESS PRACTICES.

We at Sizer Metals Pvt. Ltd., abide by government rules and egulations pertaining to anti-competitive business practices.

We follow CCI (Competition Commission of India) guidelines in business affairs.

Following are the topics wherein we don’t indulge.

  • Dumping
  • Price Fixing
  • Refusal to Deal
  • Limit Pricing
  • Tying
  • Misuse of patents
  • Cartels
  • Dividing Territories

Also covers other topics which are part of CCI guidelines.

POLICY ON PREVENTION OF MONEY LAUNDERING

A reputation for integrity, both in its business behavior and in its management systems, is crucial to us in for achievement of company’s commercial goals and to the fulfillment of the corporate responsibilities.

Sizer Metals Pvt. Ltd. is committed to the highest standards of Anti-Money Laundering and Combating Terrorism Financing (hereinafter collectively referred to as AML/CTF) compliance and requires management and employees to adhere to these standards to prevent use of the services for money laundering purposes.

The Policy on Prevention of Money Laundering and Terrorist Financing (hereinafter as the «Policy») outlines the minimum general unified standards of internal AML/CTF control which should be adhered to by Sizer Metals Pvt. Ltd. in order to mitigate the legal, regulatory, reputational and as a consequence financial risk.

Non-compliance with these laws may lead to serious consequences to the financial condition and reputation of Companies.

THE SCOPE AND APPLICABILITY

The policy is mandatory for all the employees. The company should use their best endeavors to ensure that the employees are not involved in money laundering and terrorist financing.

THE PURPOSE OF THE POLICY

The policy is designed to comply with the standards on combating money laundering and the financing of terrorism & proliferation.Money Laundering and Terrorist Financing.

Risk management A risk-based approach takes a number or all of the following steps in assessing the most cost effective and proportionate way to manage and mitigate the money laundering and terrorist financing risks faced by the company:

  • identify and assess the money laundering and terrorist financing risks that are relevant to the Company;
  • design and implement controls to manage and mitigate the assessed risks;
  • monitor and improve the effective operation of these controls.
  • Risk management generally shall be regarded as a continuous process, carried out on a dynamic basis.
  • Company therefore ensure that their risk management processes for managing money laundering and terrorist financing risks are kept under regular review. It is recommended that the Companies revisit their assessments at least annually.

The general principle of Sizer Metals Pvt. Ltd. is that, where there are higher risks, Sizer should take enhanced measures to manage and mitigate those risks; and that, correspondingly, where the risks are lower, simplified measures may be permitted.

In particular, they should increase the degree and nature of monitoring of the business relationship, in order to determine whether those transactions or activities appear unusual or suspicious.

ANTI CORRUPTION POLICY & ANTI BRIBERY

Sizer Metals Pvt. Ltd. is committed for prevention and detection of fraud, bribery and all other corrupt business practices.

It is our policy to conduct all of its business activities with honesty, integrity and the highest possible ethical standards and vigorously enforce its business practice, of not engaging in bribery or corruption.

This policy applies to all employees of Sizer Metals Pvt. Ltd including proprietor, senior executives and employees, contractors, trainees, casual workers, agents or any other person associated with Sizer Metals Pvt. Ltd

Policy details

A bribe is an inducement, payment, reward or advantage offered, promised or provided to any person in order to gain any commercial, contractual, regulatory or personal advantage. It is illegal to directly or indirectly offer a bribe or receive a bribe. It is also a separate offence to bribe a government /public official. “Government/ public official” includes officials, whether elected or appointed, who hold a legislative, administrative or judicial position of any kind in a country or territory.

A bribe may be anything of value and not just money, gifts, inside information, sexual or other favors, corporate hospitality or entertainment, offering employment to a relative, payment or reimbursement of travel expenses, charitable donation or social contribution, abuse of function and can pass directly or through a third party. Corruption includes wrongdoing on the part of an authority or those in power through means that are illegitimate, immoral or incompatible with ethical standards. Corruption often results from patronage and is associated with bribery.

CARRER DEVELOPMENT POLICY

At Sizer Metals Pvt. Ltd. We believe that career development is one of the important ac activity in order to attract and retain talented and competent employees and subsequently enhance their career satisfaction.

At Sizer Metals Pvt. Ltd. this is a well-organized and planned process to improve the efficiency of organization.

We believe that this is an effort to achieve a balance between organizational workforce requirements and individual career needs.

Employees have their own personal desires and aspirations and need to effectively utilize their personal skills to attain their career goals and objectives.

On the other hand, Sizer Metals Pvt. Ltd. have needs for staffing and meeting present and future human resource requirements.

A career development policy gives guidance for both the parties in to consideration and helps them meet their requirements as well as objectives.

Objectives of Career Development.

  • To ensure effective communication within organization:

    The main objective career development policy is to develop and strengthen communication within the organization. This policy shall promote communication at all levels of organizations from chairman to peon. We believe that effective communication is the key for solving several critical issues.

  • Helping in taking decision on careers:

    We shall provide assistance to staff members regarding career decisions.We shall help them to assess their skills and competencies and know their goals and future aspirations. It helps them give a direction so that they can focus on achieving their long term career goals.

  • Better Use of Employee Skills:

    We believe in making better use of employee skills.After completion of probation we appoint new staff members, where they will be able to produce maximum output after consulting with their immediate superiors.

  • Setting Realistic Goals:

    We believe in setting realistic goals and expectations. This ensures both employees and organization to understand what is feasible for them and how they can achieve their goals.

  • Creating a team of talented / competent employees:

    We believe creating and retaining team of talented / competent employees.

  • Enhancing the career satisfaction:

    We believe that improvement of career satisfaction of our employees.We consider employees as our valuable assets.

POLICY AGAINST DISCRIMINATION AND HARASSMENT

Sizer Metals Pvt. Ltd., prohibits discrimination, harassment and / or related retaliation in case of recruitment, treatment, trainings, promotions and all other activities.

We all at Sizer Metals Pvt. Ltd. do not discriminate among race, color, national origin, sex, pregnancy, age, disability, creed, religion, sexual orientation, gender identity, gender expression, veteran status, political affiliation, or political philosophy.

This prohibition applies to staff and all workmen, contractors and other third parties. Any violations may be subject to disciplinary action, up to and including, expulsion or termination of employment, as applicable.

Sizer Metals Pvt. Ltd shall consider what appropriate potential actions should be taken, including contract termination and / or property exclusion, regarding third party conduct that is alleged to have violated this policy; however those options may be limited depending on the circumstances of the arrangement.

Sizer Metals Pvt. Ltd shall take prompt and effective steps reasonably intended to stop any form of discrimination, harassment and / or related retaliation, eliminate any hostile environment, prevent its recurrence and as appropriate, remedy its effects.

POLICY ON FUNDAMENTAL HUMAN RIGHTS

We all at Sizer Metals Pvt. Ltd., believes in respecting human rights is basic to the sustainability of company.

Sizer Metals Pvt. Ltd is committed for ensuring that people are treated with dignity and respect.

Our human rights policy is guided by human rights principles.

To management is committed for working with and encouraging suppliers to uphold the principles in this policy and to adopt similar policies within their businesses.

Sizer Metals Pvt. Ltd. respects human rights. We are committed to identify, prevent, and mitigate adverse human rights impacts resulting from or caused by our business activities.

Top management recognizes its impact on the communities.We are committed for communication with stakeholders on human rights issues related to our business.

We value the diversity of the people with whom we work and the contributions they make. We are dedicated to maintaining workplaces that are free from discrimination or harassment on the basis of race, sex, color, national or social origin, religion, age, disability, sexual orientation, political opinion or any other status protected by applicable law.

The basis for recruitment, hiring, placement, training, compensation and advancement at the Company is qualifications, performance, skills and experience.

Regardless of personal characteristics or status, the company does not tolerate disrespectful or inappropriate behavior, unfair treatment or retaliation of any kind. Harassment is unacceptable in the workplace and in any work-related circumstance outside the workplace. These principles apply not only to Company employees but also to the business partners with whom we work.

Top management respect employees’ right to join, form or not to join a labor union without fear of reprisal, intimidation or harassment. Where employees are represented by a legally recognized union, we are committed to establishing a constructive dialogue with their freely chosen representatives.

Top management is committed for bargaining in good faith with such representatives.

Company provides a safe and healthy workplace and complies with applicable safety and health laws, regulations and internal requirements. We are dedicated to maintaining a productive workplace by minimizing the risk of accidents, injury and exposure to health risks.

PROCUREMENT POLICY-1

Sizer Metals Pvt. Ltd. do Import ferrous and non-ferrous metals from LME approved trading firms.

We believe that good working relationship with suppliers is the key to success.Clear communication of procurement policy is ensured throughout the supply chain to ensure transparency.

While procurement we shall ensure that procured materials shall be from sources which have not hampered human rights, safety or the environment.

We shall develop strong relationship with our suppliers, based on mutual trust, understanding and respect.

Our suppliers shall comply to following agenda,

  • Business principals consistent with our own.
  • Ensure that their products and services are produced and delivered to comply with all statutory and regulatory requirements related to their business.
  • Focus on continuous improvement in their supply chain relationship with us.

We are interested to work with our suppliers to,

  • Develop long term meaningful relations to the benefit of both parties.
  • Improve the quality, environmental performance and sustainability of goods and services where this can be achieved to the benefit of both parties.

PROCUREMENT POLICY-2

Following principles shall be adhered in the procurement process.

  • Fair competition

    WE shall treat all bidders with fairness and ensure that they are given the same level of information when preparing quotations or tenders.

  • Conflict of Interest

    On encountering any situations of conflict of interest it shall be communicated to related supplier as per our code of conduct.

  • Cost Effectiveness

    Offers, quotations of suppliers shall be evaluated on the basis of product quality, track records and various other factors and not only cost.

  • Transparency

    To ensure transparency offer / quotation shall contain all necessary information to facilitate submission of appropriate and competitive offer.

SUPPLIER CODE OF CONDUCT POLICY & COMPLIANCE

Introduction:

This code of conduct is applicable to all suppliers.

Definition of supplier:

Suppliers/ service providers/ vendors/ traders / agents/ consultants/ contractors/ joint venture partners/ third parties including their employees, agents and other representatives.

This policy defines basic requirements to be followed by supplier before starting business with Sizer Metls Pvt. Ltd.

This policy ensures our commitment to abide global guidelines & standards such as International Labour Organization, United Nations’ Universal Declaration of Human Rights and other business related statutory requirements concerning Environment Protection, Minimum Wages, Child Labour, Anti-Bribery, Anti Corruption, Health and Safety.

  • Ethical Conduct

    Representatives of suppliers shall deal with professionalism, honesty and integrity, as well as high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be as such by third parties.

  • Labour & human rights

    We shall ensure that suppliers comply with all applicable local, state and national laws regarding human rights.

    Suppliers shall ensure that all their employees are hired on their own free will and guarantee that all their operations are free from forced, bonded, compulsory, indentured, prison labour or any other form of compulsory labour and child labour.

    Supplier shall ensure that all its employees are provided equal employment opportunities, an environment conducive to their growth, free from any form of discrimination and harassment.

    Supplier shall ensure compliance with minimum working hours and minimum wages prescribed by applicable laws and regulations.

    Suppliers must ensure they have taken steps to ensure their business operations are free from slavery and human trafficking practices.

  • Health, safety & environmental sustainability

    Supplier shall ensure safe and healthy working environment to employees and comply with all applicable laws and regulations regarding working conditions.

    Supplier shall adhere to Environmental, Health and Safety and other operational policies of the Company while executing any work or contract at the company site.

    Supplier shall follow all laws of the land.

    Anti-Bribery: The supplier shall not, directly or through intermediaries, take any recourse to any unethical behavior.

  • Supplier shall not offer or accept bribe or use other means of obtaining undue or improper advantage, offer or accept any kickbacks.
  • Supplier shall not enter into a financial or any other relationship with a Sizer Metals Pvt. Ltd. employee that creates any actual or potential conflict of interest for Sizer.
  • The Supplier shall communicate to Sizer any situation where an employee or professional under contract with Sizer may have an interest of any kind in the supplier’s business or any kind of economic ties with the Supplier.
  • Gifts and donations:

    The supplier shall not (directly or indirectly) offer any gift, entertainment, trip, discount, service, or other benefit from his organization to any official of Sizer Metals Pvt. Ltd. which would or reasonably appear to be capable of influencing such person to act in a manner which is against the interest of the Sizer Metals Pvt. Ltd.

  • Intellectual property

    The supplier follows adequate measures in order to safeguard and not infringe any confidential and proprietary information/intellectual property/ technology which come to its knowledge during the course of its business relationship/ dealings with Sizer Metals Pvt. Ltd.

    In case of sub-contracting, sharing of confidential information should be made with the consent of Sizer Metals Pvt. Ltd.

  • Third party representation

    The suppliers are not be allowed to represent Sizer Metals Pvt. Ltd. or to use Sizer’s brands without the written permission of Sizer Metals Pvt. Ltd.

  • Supplier’s compliance commitment

    Sizer Metals Pvt. Ltd. expects that suppliers shall comply all applicable laws and regulations.

    Sizer Metals Pvt. Ltd. reserves the right to conduct a full audit if necessary to ensure compliance of Supplier Code of Conduct.